Subject: Comment Letter for File Number S7-31-22 Order Competition Rule
From: Devin Morgan
Affiliation:

Mar. 29, 2023

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Dear Securities and Exchange Commission,
I am writing to express my strong support for the proposed changes to the Order Competition Rule. As an investor, I have experienced first-hand the challenges that retail investors face in the current market structure.
Retail investors have no control over their own trade executions as a "peer" is overseeing and conducting the true order placement. This happens on and off exchange, and dark markets are not in favor of retail investors. Currently, payment for order flow feeds these peers the ability to choose market conditions, giving them an unfair advantage over the retail investor.
As a victim of the algorithm that fulfills orders t+ and reroutes volume to obey algo price distribution, I can attest that even if a trader is successful and plays the cycles of liquidity (when things are due at the clearing house DTCC) and invests to attempt to find the volume distribution period, even when successful, they are still not true reflections of price. If gains are lost, the wash sale rule hurts the retail even more.
It is important that the SEC considers changing how the market really works and the perception of how people think the market works. Currently, the market is structured in a way that favors the 10% of investors who have access to sophisticated algorithms and trading strategies. These investors use high-frequency trading and other tactics to manipulate the market in their favor. Meanwhile, retail investors are left in the dark, with little understanding of how the market truly operates.
Moreover, it is worth noting that these peers are protected through arbitration and billions of dollars that were grey-lined earned. This means that they are able to act with impunity, despite engaging in practices that are often at odds with the interests of retail investors.
Overall, I believe that the proposed changes to the Order Competition Rule would be a step in the right direction towards creating a more equitable market structure for all investors. By reducing the influence of payment for order flow and providing greater transparency and fairness in the market, we can ensure that investors of all backgrounds are able to make informed decisions and achieve their financial goals.
Thank you for considering my comments.
Sincerely, Devin James Morgan